*Hassan Ahmed
I. Introduction
On June 6, 2025, United States District Judge Claudia Wilken issued an order granting the final approval of the settlement agreement in College Athlete NIL Litigation.[1] This long-awaited settlement brings a resolution to three consolidated antitrust cases against the National Collegiate Athletic Association (“NCAA”): House v. NCAA, Oliver v. NCAA, and Carter v. NCAA[2] (collectively referred to as the House settlement). These lawsuits, brought by student-athletes, alleged that the NCAA rules barred or restricted them from receiving compensation in exchange for the use of their name, image, and likeness (“NIL”), in clear violation of the Sherman Antitrust Act.[3]
While this landmark multi-billion-dollar settlement is intended to provide back pay to student-athletes and create a framework for future compensation,[4] it simultaneously raises questions about the future of college athletics and the evolving legal landscape.[5]
II. Overview: Key Terms and Provisions of the House Settlement
The House settlement requires the NCAA and its five major conferences to pay approximately $2.8 billion in back pay over the span of the next ten years.[6] The damages for back pay will be distributed to hundreds of thousands of student-athletes who participated in collegiate sports dating back to 2016.[7] The settlement also introduces a revenue-sharing model allowing colleges and universities to pay student-athletes their share of athletic revenues “from media rights, ticket sales, and sponsorships.”[8] The revenue-sharing is currently capped at 22% of average revenue, or $20.5 million per school for the 2025-26 academic year.[9] The revenue cap increases 4% annually over the next two years, then is recalculated every three years during the duration of the agreement.[10]
The House settlement will also replace the NCAA’s current system of sport-specific athletic scholarship limits with sport-specific roster limits instead.[11] In addition to compensating athletes, this change may allow schools to offer full or partial scholarships to every athlete on their rosters, but limits the total number of roster spots per team, depending on the sport.[12] “Designated student-athletes” already committed to play this academic year will not be impacted by this rule change and will retain their roster spots.[13] Colleges and universities from other conferences have the choice to opt into the NIL revenue-sharing settlement over the ten-year settlement period, subjecting them to the same regulations and roster limits.[14] Schools that opt out of the revenue-sharing model are not permitted to pay their athletes, and are not subject to the new scholarship or roster restrictions.[15]
To oversee compliance with the House settlement terms, the College Sports Commission (CSC) has been created to regulate matters related to athlete compensation.[16] The CSC is responsible for reviewing all NIL deals over $600 between Division I student-athletes and unaffiliated third-parties to ensure they serve “a valid business purpose and do not exceed a reasonable range of compensation.”[17] The CSC will utilize NIL Go, an online portal built specifically for this purpose, to ensure compliance with the settlement terms related to unaffiliated third-party NIL deals.[18] If the deal is not approved by the CSC, student-athletes will have the option to modify and resubmit the deal, withdraw from the agreement, or challenge the CSC’s decision through a neutral arbitration process.[19]
III. Future Implications and the Evolving Landscape of College Athletics
Although the House settlement resolves several antitrust challenges to NCAA rules, numerous legal questions remain as the landscape of collegiate athletics continues to evolve.[20] One consideration is that schools opting into the settlement have allocated a substantially larger share of the revenue for male athletes, making Title IX litigation likely in the coming months and years to address gender equity concerns.[21] There are also significant concerns for non-revenue generating collegiate sports, as the economic incentives driving the changing collegiate landscape may also harm the development of amateur athletes for Olympic sports.[22] Navigating these shifts will become more difficult due to inconsistent state laws impacting collegiate sports.[23] The status of athletes, as either true amateurs or employees for the universities for which they compete, further complicates matters as students-athletes now receive compensation for their NIL rights, but not directly in exchange for their athletic performance.[24]
The regulatory framework introduced with the House settlement does not address all the challenges in college athletics and will continue to evolve.[25] There have been bipartisan efforts in Congress to create a national standard for NIL deals for student-athletes through the SCORE (“Student Compensation and Opportunity through Rights and Endorsements”) Act.[26] Echoing many of the goals of the SCORE Act, President Donald Trump issued a separate Executive Order on July 24, 2025, titled “Saving College Sports,” which seeks to reshape and overhaul collegiate athletics by providing more stability to protect future student-athletes .[27]
IV. Conclusion
The House settlement is the latest development representing the continued shift in collegiate athletics: although it creates a regulatory framework to provide long-overdue compensation to student athletes,[28] it also raises numerous unresolved questions and is likely to be the subject of future litigation.[29] How these unprecedented times will shape the legal landscape of collegiate sports through litigation and legislation remains to be fully seen.[30]
*Hassan Ahmed is a second-year student at the University of Baltimore School of Law where he is a Staff Editor for Law Review, a member of the Royal Graham Shannonhouse III Honor Society, and a UB LEADs Mentor. In the summer of 2025, Hassan worked as a Summer Associate for Baker, Donelson, Bearman, Caldwell & Berkowitz P.C., and is looking forward to returning next summer. In the spring of 2026, Hassan will serve as a Judicial Intern for The Honorable George L. Russell III, Chief District Judge for the U.S. District Court for the District of Maryland.
[1] In re College Athlete NIL Litigation, No. 20-CV-03919 CW, 2025 WL 1675820, at *45 (N.D. Cal. June 6, 2025).
[2] Id. at *3-4. The five major NCAA Conferences were also named Defendants in the action: The Pac-12, Big Ten, Big 12, SEC, & ACC. Id. at *1.
[3] See Jeff Cohen, The House Settlement: College Athletics Panacea or Pandora’s Box?, JD SUPRA (July 17, 2025), https://www.jdsupra.com/legalnews/the-house-settlement-college-athletics-6184743/.
[4] Id.
[5] See Kyle Ritchie, The Evolving Landscape of College Student-Athlete Compensation, NYSBA (Mar. 26, 2025), https://nysba.org/the-evolving-landscape-of-college-student-athlete-compensation/.
[6] Dan Murphy, Judge OK’s $2.8B Settlement, Paving Way for Colleges to Pay Athletes, ESPN (June 6, 2025, at 21:28 ET), https://www.espn.com/college-sports/story/_/id/45467505/judge-grants-f. inal-approval-house-v-ncaa-settlement.
[7] See Mike Scarcella, US Judge Approves Settlement Allowing NCAA Schools to Pay Athletes, Reuters (June 9, 2025, at 05:24 ET), https://www.reuters.com/sports/us-judge-approves-landmark-28-billion-ncaa-settlement-with-athletes-2025-06-07/.
[8] Id.
[9] Id.
[10] Id.
[11] See Steve Berkowitz, What Does the NCAA Settlement Mean for College Sports? We Answer the Burning Questions, USA TODAY (June 7, 2025, at 06:01 ET), https://www.usatoday.com/story/sports/college/2025/06/07/ncaa-revenue-sharing-settlement-questions/83221673007/.
[12] See, e.g., Roster Limits, Coll. Sports Comm’n, https://www.collegesportscommission.org/roster-limits (last visited Oct. 6, 2025).
[13] Id.
[14] See Courtney Rickard, The House v. NCAA Settlement Explained: What It Means for the Future of Pay for College Student-Athletes, HONESTGAME: Blog (Sep. 23, 2025), https://honestgame.com/blog/house-vs-the-ncaa/.
[15] Id.
[16] See Will Backus, What is NIL Go? Explaining the College Sports Commission’s Initiative to Monitor Name, Image and Likeness, CBS SPORTS (July 10, 2025, at 12:45 ET), https://www.cbssports.com/college-football/news/what-is-nil-go-explaining-the-college-sports-commissions-initiative-to-monitor-name-image-and-likeness/.
[17] Student-Athlete NIL Deals, Coll. Sports Comm’n, https://www.collegesportscommission.org/nil (last visited Oct. 6, 2025).
[18] Id.
[19] Id.
[20] See Josh Moody, What Happens to NCAA Athletes Now?, Inside Higher Ed (June 30, 2025), https://www.insidehighered.com/news/business/revenue-strategies/2025/06/30/college-athletics-enters-uncharted-territory-july-1.
[21] See Justin Williams, How Could Title IX Impact NIL and Revenue Sharing in College Sports?, N.Y. Times: The Athletic (Mar. 18, 2025), https://www.nytimes.com/athletic/6144055/2025/02/18/title-ix-nil-revenue-sharing-college-sports-effect-explained/.
[22] See Ross Dellenger, Historic House-NCAA Settlement Leaving Hundreds of Olympic Sport Athletes in Peril, yahoo! sports (Oct. 25, 2024), https://sports.yahoo.com/historic-house-ncaa-settlement-leaving-hundreds-of-olympic-sport-athletes-in-peril-125238713.html.
[23] See Nicole Auerbach, NCAA Says Schools Must Comply with Its NIL Rules in States with Conflicting Laws, N.Y. Times: The Athletic (June 27, 2023), https://www.nytimes.com/athletic/4644949/2023/06/27/ncaa-nil-rules-state-laws/.
[24] See Michael McCann, Fight to Recognize College Athletes as Employees Lives On, Sportico (Jan. 13, 2025, at 05:55 ET), https://www.sportico.com/law/analysis/2025/college-athlete-employee-legal-fight-1234823597/.
[25] See Moody, supra note 20.
[26] See Ralph D. Russo & Chris Vannini, SCORE Act Advances Through Committee, Moving College Sports Reform Closer To House Floor, N.Y. Times: The Athletic (July 25, 2025), https://www.nytimes.com/athletic/6511289/2025/07/23/score-act-congress-college-sports/; SCORE Act, H.R. 4312, 119th Cong. (2025).
[27] See Gregory Svirnovskiy, The Fight over the Future of College Football is Here. Enter Donald Trump., POLITICO (Sep. 2, 2025, at 12:35 ET), https://www.politico.com/news/2025/08/30/trump-republicans-ncaa-college-football-score-act-00531260; Exec. Order No. 14322, 90 Fed. Reg. 35821 (July 24, 2025).
[28] See supra Part II.
[29] See supra Part III.
[30] See Ritchie, supra note 5.
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